### 1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.



### IN THE MATTER OFTHE PETITIONFOREXEMPTION OF: RSA MARKETING FORAN EXEMPTION SEEKINGRELIEFFROMTHEREQUIREMENTS OF TITLE 14 OFTHE CODE OFFEDERALREGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

### (a)(2), AND 91.417(a) & 

### (b) CONCERNING COMMERCIAL OPERATION OFDJIPHANTOM3PROFESSIONAL AND DJIINSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATIONAND REFORMACT OF2012 (PUBLIC LAW 112-95) Submitted onJune 12,2015 RSA Marketing 400 S Commerce Wichita, KS 67202 Tel: (316) 977-9600

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TABLE OF CONTENTS Page
GLOSSARY OF ABBREVIATIONS 3
SUMMARY 4
INTRODUCTION AND INTERESTS OF PETITIONER 4
BACKGROUND 4
BASIS FORPETITION 5
NAME AND ADDRESS OF PETITIONER 6
THE SPECIFIC SECTIONS OF 14 C.F.R. FROMWHICH RSAMARKETING 7 SEEKS EXEMPTION
THEEXTENT OF RELIEF RSA MARKETING SEEKS AND THE REASON 10 RSAMARKETING SEEKS THE RELIEF
THE REASONS WHY GRANTINGRSA MARKETINGS' REQUEST WOULD 13 BEIN THEPUBLIC INTEREST
THEREASONS WHY GRANTINGTHE EXEMPTION WOULD NOT 15 ADVERSELY AFFECT SAFETY
SUMMARYTHAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 26
ANYADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE 26 TO SUPPORT RSA MARKETING'S REQUEST
CONCLUSION 28 APPENDICES 293
GLOSSARY OFABBREVIATIONS AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL Above Ground Level Area ofInterest Air Traffic Control AirTraffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual FlightRules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing4
SUMMARY RSAMarketing seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate anUnmanned Aircraft System (UAS) pursuantto Section 333 oftheFAAModernization and Reform Act of2012 (FMRA). This exemption will permitRSA Marketingto operate a UAS for the commercial purpose ofconducting aerial video and photography for commercial filming over certain areas ofthe United States. INTRODUCTION AND INTERESTS OF THE PETITIONER RSA Marketing provides its clients with expertise and knowledge in advancedtechnologies and solutions to increase efficiency, productivity and effectiveness. RSA Marketing also provides its clients withthe highest quality digital content for use in their commercial, personal, and non-profit multimediaprojects. RSA Marketing has five years ofprofessional experience in commercial videography and photography for promotions, commercials, long-form corporate and productvideos, promotion ofboth private and community events, and is recognized as an expert in this field. RSA Marketing has more than two years ofrecreational/hobby experience in all aspects ofaerial video and photography. The objective ofRSAMarketing's aerial video and photography operations is to provide high-quality imaging for clients ranging from health care to manufacturing, retail, law and industrial, specifically targeting: Increase direct employment related to commercial video production in Wichita, KS. RSA Marketing plans to add up to three (3) additional full-time staffoverthe next 12 months related tothe operation ofthe UAS.

· Achieve high-quality, locally accessible and cost-efficient marketing communications effective in the growth oflocal businesses and their local employment. Improve the ability ofthe local video production industry to compete nationally. Increase public knowledge ofUAS and promote safe UAS operations.

BACKGROUND UnmannedAircraft Systems: DJI Phantom 3 ProfessionaL DJI Inspire 1UASs RSAMarketing seeks an exemptionto operate DJI systems for compensation orhire within the National Airspace System (NAS). The DJI Phantom 3 Professional and DJI Inspire 1are vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control5 Station (GCS) utilizing electronic tablet or smartphone systems. The DJI Phantom 3 Professional has a maximum gross weight ofapproximately 2 pounds 8 ounces, while having a diagonal length of23 inches, height of8 inches, and a maximum speed of approximately 31 knots. The DJI Inspire 1has a maximum gross weight of6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed ofapproximately 42 knots. The DJI Phantom 3 Professional and DJI Inspire 1UAs are equipped withfour main Lithium Polymerbattery powered electric motors. The DJI Phantom 3 Professional and DJI Inspire 1UAs thatwill be operated by RSA Marketing will be registered in accordance with49 U.S.C. 44103,Registration of Aircraft, as well as 14 C.F.RPart47,AircraftRegistration, and marked in accordance with 14 C.F.R. Part45, Identification andRegistrationMarking. BASIS 

### FORPETITION Petitioner, RSA Marketing, pursuantto the provisions ofthe Federal AviationRegulations (FAR) (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, SpecialRules for Certain UnmannedAircraftSystems, hereby petitions the Administratorto commercially operate the DJI Phantom 3 Professional Vision+, DJI Inspire 1UASs in theNational Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Inconsideration ofthe speed, weight, size, and limited operating area associated withthe unmanned aircraft and its operation, RSA Marketing's operation ofDJI Phantom 3 Professional and DJI Inspire 1 UASs meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part21, SubpartH. Accordingly, RSAMarketing requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. RSA Marketing submits thatthe requested relief is proper since an equivalent level ofsafety will be ensured. RSA Marketing will use experienced personnel ortechnicians to perform maintenance, alterations, orpreventive maintenance onthe UASs using the methods, techniques, and practices prescribed in the operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire1InstructionManual). Furthermore, RSAMarketingwill document and maintain all maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1UASs. Relieffrom certainrequirements ofSection 61.113(a) and (b), entitledPrivatepilot privileges andlimitations: Pilot in command, is requested by RSA Marketingto the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight-hour and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 3 Professional and DJI Inspire 1UASs in a manner consistentwiththis exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles, and structures.

### 6 RSAMarketing seeks relieffrom Section 91.7(a), entitled Civilaircraftairworthiness, because the DJI Phantom 3 Professional and DJI Inspire 1UASs do notrequire an airworthiness certificate in accordance with 14 C.F.R. Part21, Subpart H. As such, RSA Marketing submits that itwill ensure thatthe DJI Phantom 3 Professional and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance withthe operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1InstructionManual), and thatthe aircraft are in a condition for safe flight. RSAMarketing also seeks an exemption from the requirements ofSection 91.121, entitled AltimeterSettings, as the DJI Phantom 3 Professional and DJI Inspire 1UAs will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 3 Professional and DJI Inspire 1UAs will be providedto the PIC viaGlobal Positioning System (GPS) equipment and radio communications telemetry datalink, which downlinks from the UAto the GCS for active monitoring ofthe flight path. This altitude information, combined withRSAMarketing's operation ofthe DJIPhantom 3 Professional and DJI Inspire 1UASs withinVisual Line ofSight (VLOS), at orbelow 500 feet Above Ground Level (AGL), will ensure a level ofsafety equivalentto Section 91.121. Additionally, RSAMarketing seeks an exemption from the requirements ofSection 91.151(b), entitledFuel requirements for flight in T-'FR conditions. RSAMarketing submits that safety will notbe affected by operation ofthe DJI Phantom 3 Professional and DJI _Inspire 1UAs during daylighthours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enoughbattery powerto fly for a total duration of approximately 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least4.5 minutes. Inaccordance with 14 C.F.R. § 11.81, RSA Marketing provides the following information in support ofits petition for exemption: A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner and point ofcontact is: Bruce Rowley RSAMarketing 400 S. Commerce Wichita, KS 67202 Tel: (316) 977-9600 Email: browley@rsaconnect.com
B. The Specific Sections Of14 C.F.R. from Which RSA Marketing Seeks Exemption. 1. RSA Marketing Seeks Exemption From The Requirements Of Section 61.113(a) And (b).7 Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No personwho holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation orhire, act as PIC ofan aircraft. (b) A private pilotmay, for compensation or hire, act as PIC ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation orhire.
2. RSA Marketing Seeks Exemption From The Requirements OfSection 91.7(a).
Section 91.7, entitled Civilaircraftairworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. 3. RSA Marketing Seeks Exemption From The Requirements OfSection 91.121.
Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Eachperson operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeterthat is set, when operating: (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting ofa station alongthe route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station withinthe areaprescribed in paragraph (a)(1 )(i) ofthis section, the currentreported altimeter setting ofan appropriate available station; or (iii) Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 4. RSA Marketing Seeks Exemption From The Requirements OfSection 91.15l(b). Section 91.151, entitledFuel requirements for flight in VFR conditions, subsection (b), states the following:8 (b) Noperson may begin aflight in a rotorcraft under VFR conditions unless (considering windand forecastweatherconditions) there is enough fuel tofly to thefirstpointof intendedlandingand, assumingnormalcruisingspeed, tofly after that for atleast20 minutes. 5. RSA Marketing Seeks Exemption From The Requirement OfSection 91.405(a).
Section 91.405, entitledMaintenance required, subsection (a), states the following: Each owner or operator ofan aircraft: (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 6. RSA Marketing Seeks Exemption From The Requirements OfSection 91.407(a)(l)
Section 91.407, entitled Operation aftermaintenance,preventive maintenance, rebuilding, oralteration, subsection (a)(1 ), states the following: (a) No person may operate any aircraftthathas undergone maintenance, preventive maintenance, rebuilding, or alterationunless: (1) Ithas been approved for returnto service by a person authorized under §43.7 ofthis chapter[.]
7. RSA Marketing Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2).
Section 91.409, entitledInspections, subsection (a), statesthe following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, withinthe preceding 12 calendar months, it has had: (1) An annual inspection in accordance with part 43 ofthis chapter andhas been approved for returnto service by a person authorized by§ 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance withpart21 ofthis chapter. 8. RSA Marketing Seeks Exemption From The Requirements OfSections 91.417(a) And 91.417(b).

### 9 Section 91.417, entitledMaintenance records, subsections (a) and (b), state the following: (a) Except for workperformed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include: (i) A description (orreference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraftfor returnto service. (2) Records containingthe following information: (i) The total time in service ofthe airframe, each engine, eachpropeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under whichthe aircraft and its appliances are maintained. (v) The current status ofapplicable Airworthiness Directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alterationto the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed:

### 10 (1) The records specified inparagraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for one year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner oroperator under§ 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for returnto service. C. 

### The Extent OfReliefRSA Marketing Seeks And The ReasonRSA Marketing Seeks TheRelief.
1. Extent OfReliefRSA Marketing Seeks AndTheReason RSA Marketing Seeks ReliefFrom Section 61.113(a) And (b).
Relieffrom Section 61.113(a) and (b) entitledPrivatepilotprivileges andlimitations: Pilot in command, is requested to the extent necessary to allow a PilotIn Command (PIC) holding a private pilot orhigher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conductthe proposed UAS flight operations for compensation orhire. This reliefis requested since the limitations setforth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC ofan aircraft in connectionwith any business or employment if: (1) The flight is only incidental to thatbusiness or employment; and (2) The aircraft does not carry passengers or property for compensation orhire. As setforth more fully below, RSA Marketing submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS or DJI Inspire 1UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional or DJI Inspire 1UAS in a manner consistentwiththe operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles, and structures. Further, RSA Marketing submits that all flights oftheDJI Phantom 3 Professional and DJI Inspire 1UASs, conducted by the PIC pursuantto the grant ofthisPetition: (1) will be incidental to RSAMarketing's business; and (2) will not carry passengers or property for compensation orhire.11 

### 2. Extent OfReliefRSA Marketing Seeks And TheReason RSA Marketing Seeks ReliefFrom Section91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraftairworthiness, is requested to the extent required to allowRSA Marketing to determine thatthe DJI Phantom 3 Professional and DJI Inspire 1UASs are in airworthy conditionprior to every flight by ensuring that the UAS is in compliance withthe operating documents (i.e., the RSA Marketing Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire1 Instruction Manual). RSA Marketing seeks the requested reliefbecause the DJI Phantom 3 Professional and DJI Inspire 1UASs do notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, RSA Marketing will ensure that the DJI Phantom 3Professional and DJI Inspire 1UASs are in airworthy condition based upon its compliance withthe operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1Instruction Manual) prior to every flight, and further, determine thatthe aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

### 3. Extent OfReliefRSA MarketingSeeks And TheReason RSA MarketingSeeks ReliefFromSection 91.121. Relieffrom Section 91.121, entitledAltimetersettings, may be required to allowflight operations ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the Unmanned Aircraft (UA) to the Pilot In Command (PIC) at the Ground Control Station (GCS). Since the FAArequires that any altitude information concerningUAS operations be reported to air traffic control (ATC) in feet Above Ground Level (AGL), RSA Marketing seeks the requested reliefbecause the DJI Phantom 3 Professional and DJI Inspire 1UA's altimeter may be set onthe ground to zero feet AGL, rather thanthe local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extentnecessary to comply withthe applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 3Professional and DJI Inspire 1UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to eachflight, and provides the PIC with altitude information ofthe UA onthe heads-up display ofthe GCS. 

### 4. Extent OfReliefRSA Marketing Seeks And TheReason RSA Marketing Seeks ReliefFrom Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFRconditions, is requested to the extentrequired to allow flights ofthe battery powered DJI Phantom 312 Professional and DJI Inspire 1UAs during daylight hours invisual meteorological conditions (VMC), underVisual FlightRules, for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. RSA Marketing seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe battery powered DJI Phantom 3 Professional and DJI Inspire 1UAs will severely constrainthe practicality ofany aerial video or still photo flight operations that RSA Marketing proposes to conduct pursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs, the DJI Phantom 3 Professional and DJI Inspire 1 operating documents, and RSA Marketing's proposed operating limitations, ensure that RSA Marketing will safely operate the battery powered DJI Phantom 3 Professional and DJI Inspire 1UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery powerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least4.5 minutes. 5. Extent OfReliefRSA MarketingSeeksAnd TheReasonRSA MarketingSeeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b).
Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, RSA Marketing requests relieffrom these Sections because the DJI Phantom 3 Professional and DJI Inspire 1UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional and DJI Inspire 1UASs meetthe conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, RSA Marketing will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed inthe UAS operating documents (i.e., the RSAMarketing Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1InstructionManual). Furthermore, RSA Marketing will document and maintain all maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1UASs.
D. The Reasons Why GrantingRSA Marketing'sRequestWould Be InThe Public Interest; That Is, How ItWould BenefitThe PublicAs A Whole. Granting the present petition will further the public interestby allowing RSA Marketingto safely, efficiently, and economically perform aerial video and photography for value creation in a wide range ofbusinesses that are critical to the health ofthe local economy.13 Additionally, use ofthe DIT Phantom 3 Professional and DJI Inspire 1UASs will decrease congestion oftheNAS and reduce pollution. Notably, the benefits ofRSAMarketing's proposed operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs will be realized without implicating any privacy issues. 

### 1. 

### ThePublicWillBenefitFrom Decreased Congestion OfThe NAS. The DJI Phantom 3Professional and DJI Inspire 1UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 3 Professional or DJI Inspire 1UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the air and onthe ground. Furthermore, by reducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 Professional and DJI Inspire 1UAs do not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control duringthe ground, takeoff, departure, arrival, and landing phases offlight operations.


### 2. The PublicWill BenefitFromThe SafetyAnd Efficiency OfThe DJIPhantom 3 Professional and DJIInspire 1UASs. Conducting aerial acquisitions withthe DJI Phantom 3 Professional andDJI Inspire 1 UASs, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Byusingbattery power and electric motors, the DJI Phantom 3 Professional and DJI Inspire 1UASs produce no air pollution, and is the mostviable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately 20-30 gallons perhour ofleaded aviationfuel. The DJI Phantom 3 Professional and DJI Inspire 1UAs, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 Professional and DJI Inspire 1UASs to perform aerial acquisitions, the substantial risk to life and property in the air and onthe ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crewmembers located onboard the aircraft, the DJI Phantom 3 Professional and DJI Inspire 1UAs (weighing approximately 2 pounds 13 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights, with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and withno fuel on board), has less physical potential for14 collateral damage to life and property onthe ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and afuel capacity of 180 gallons). 

### 3. PerformingAerialVideo and Photography Operations\Vith The DJIPhantom 3 Professional andDJIInspire 1UASs Will BenefitThe Economy. In additionto being safe and efficient, the DJI Phantom 3Professional and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs will allowUnited States based companies, like RSAMarketing, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental ProtectionAgency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in orderto remain competitive. Operating the battery powered DJI Phantom 3 Professional and DJI Inspire 1UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the DJI Phantom 3 Professional and DJI Inspire 1UASs, companies such as RSA Marketing, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal taxrevenues; and allows companies to invest in research and development in orderto remain competitive both in the United States and abroad. 

### 4. ThereAre No PrivacyIssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, RSA Marketing's proposed operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional and DJI Inspire 1UASs will be operated only in compliance with operating documents (i.e. the RSA MarketingAerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1InstructionManual) which requires property owner involvement, as well as local law enforcementnotification, and in accordance with the Federal AviationRegulations (FAR), including the minimum altitude requirements of 14 C.F.R. § 91.119. 

### E. 

### The Reasons Why GrantingThe ExemptionWouldNotAdversely Affect Safety, Or HowThe ExemptionWouldProvide A Level OfSafetyAtLeastEqualTo That ProvidedBy The Rule FromWhich RSA Marketing Seeks Exemption.15


### 1. Reasons WhyThe DJI Phantom 3 Professional and DJI Inspire 1UAs Meet The Conditions OfThe FAA Modernization and ReformAct of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated withthe unmanned aircraft and its operation, RSA Marketing's operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart 

### H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General--Notwithstandingany other requirement of this subtitle, andnot later than 180 days after the date of enactmentof thisAct, the Secretary ofTransportation shall determine 

### if certain unmannedaircraftsystems mayoperate safely in the nationalairspace system before completion of theplanandrulemaking required bysection 332 of thisActor the guidance requiredbysection 334 of thisAct. (b) AssessmentofUnmannedAircraftSystems--In making the determination under subsection (a), the Secretaryshalldetermine, ata minimum: (I) which types of unmannedaircraftsystems, 

### if any, as a result of theirsize, weight, speed, operationalcapability,proximity to airports andpopulatedareas, andoperation within Visual Line of Sight (VLOS) do notcreate a ha::ardto users of the nationalairspace system or thepublic orpose a threat to nationalsecurity; and (2) whethera certificate of waiver, certificate of authori:;ation, orairworthiness certification undersection 44704 of title 49, UnitedStates Code, is required for the operation of unmannedaircraftsystems identifiedunderparagraph (1). (c) Requirements for Safe Operation--If the Secretarydetermines under this section that certain unmannedaircraftsystems mayoperate safely in the nationalairspace system, the Secretary shallestablish requirements for the safe operation of such aircraftsystems in the nationalairspace system. In seekingthis exemption, RSA Marketing submits that the DJI Phantom 3 Professional and DJI Inspire 1UASs can operate safely inthe NAS pursuantto FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 3 Professional and DJI Inspire 1 UASs; (b) the pilot certificationrequirement; and (c) the specific operating limitations.

a. The Specifications OfThe DJIPhantom 3 Professional and DJI Inspire 1UASs Demonstrate Its Safe Characteristics.16
The DJI Phantom 3 Professional and DJI Inspire 1UASs do not create a hazard to users of the NAS or the public, or otherwise pose athreat to national security considering its size, weight, speed, and operational capability. 

### i. Technical Specifications OfThe DJIPhantom3 Professional andDJIInspire 1 UASs. The technical specifications ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs are set forth by the DJI Phantom 3 Professional and DJI Inspire 1Specifications and Data Sheet, attached hereto as ExhibitA and B. 

### ii. The DJIPhantom3 Professional and DJIInspire 1UASs Autonomous FlightAnd Navigation Modes EnableThe UASs To RemainWithinA Defined OperationalArea. The DJI Phantom 3 Professional and DJI Inspire 1UASs may be operated in both manual and fully-autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs is provided atpages 25-35 ofthe DJI Phantom 3 Professional and pages 12-16 and 45-50 oftheDJI Inspire 1 User Manuals, attached hereto as Exhibit C and D. 

### iii. The DJIPhantom3 Professional andDJIInspire 1UASs Are Designed For ·AutomaticReturnTo Home Point OrHoverInThe Event OfLoss OfThe Control

LinkOrNavigation. Whenthe Control Link is lost, the DJI Phantom 3 Professional and DJI Inspire 1UAs will remain stationary, in flight, for three seconds or more. If, afterthree seconds, the DJI Phantom 3 Professional and DJI Inspire 1UAs do not reacquire control link data from the GCS, the UAs will assume thatthe Control Link is lost and the UAs will return to the home position (i.e. failsafe mode) via GPS, and will descend to the takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 3 Professional UAS are set forth at pages 27 through 29 and for the DJI Inspire 1at pages 13 through 15 ofthe DJI Phantom 3 Professional and DJI Inspire 1UserManuals, attached hereto as ExhibitC and D. 

### iv. The DJIPhantom 3 Professional andDJIInspire 1 GCSAnd Its Operation. A complete description ofthe operation and specifications oftheDJI Phantom 3 Professional and DJI Inspire 1GCS and flight control software is provided at pages 32 through 43 ofthe DJI Phantom 3 Professional User Manual and pages 40 through 47 ofthe DJI Inspire 1User Manual. DJI Phantom 3Professional and DJI Inspire 1User Manuals are attached hereto as Exhibits C and D.17 b. Flight Operations OfDJIPhantom 3 Professional and DJI Inspire 1UASs Are Limited To The Line OfSight OfA Certificated Pilot in CommandWith A Safety Observer. RSA Marketing will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a PilotInCommand (PIC) ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights OfDJI Phantom 3 Professional and DJI Inspire 1UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seekingthis exemption, RSAMarketing proposes to commercially operate DJI Phantom 3 Professional and DJI Inspire 1UASs for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations: 1. Operations authorized by this grantofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Professional and DJI Inspire 1UnmannedAircraft Systems. Proposed operations ofany other aircraft will require a newpetition or a petitionto amend this grant. 2. UAS operations under this exemptionwill be limited to conducting operations for the purpose ofaerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA mustbe operated at an altitude ofno more than400 feet Above Ground Level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated withinVisual Line ofSight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations mustutilize a Safety Observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transferhis or her designation for the duration ofthe flight. The PIC mustensure thatthe SO canperform the functions prescribed in the operating documents.18
8. The SO must notperform any other duties beyond assisting the PIC with seeing and avoiding other airtraffic and other ground-based obstacles/obstructions and is notpermitted to operate the cameraor other instruments. 9. The operating documents and the grant ofexemption mustbe accessible during UAS operations and made available to the Administrator uponrequest. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemptiontake precedence and mustbe followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. Itis the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also presentupdated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendmentto its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 10. Priorto each flight, the PIC must inspectthe UAS to ensure that it is in a condition for safe flight. Ifthe inspectionreveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. The Ground Control Station (GCS) must be included in the preflight inspection. All maintenance and alterations mustbe properly documented in the aircraftrecords. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g. replacement ofa flight critical component) mustundergo a functional test flight. The PIC who conducts the functional test flight mustmake an entry in the aircraftrecords. 12. The pre-flight inspection must account for all potential discrepancies (e.g. inoperable components, items, or equipment) not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted inthe aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service.19 15. EachUASs operated under this exemptionmust comply with all manufacturer Safety Bulletins. 16. The authorized personmust make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC mustpossess at least a private pilot certificate and at least a current third-class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteriaand demonstrates the ability to safely operate the UAS in a manner consistentwith howthe UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualificationflight hours must be logged in a manner consistentwith 14 C.F.R. § 61.51(b). Flights for the purposes oftraining the operator's PICs are permitted underthe terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency and experience-building flights, all persons not essential for flight operations are considered nonparticipants and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under Visual Meteorological Conditions (VMC). If flight at night is required, a special request will be made atthe FAA office closestto proposed area ofoperations. Flights under Special Visual FlightRules (SVFR) are not authorized. 20. The UA may not operate within five nautical miles ofan airport reference point as denoted on a currentFAA-published aeronautical charts unless a letter ofagreement with that airport's management is obtained and the operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the operator's Certificate ofWaiver or Authorization (COA). The letter ofagreement withthe airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than2,000 feet horizontally from a cloud or when visibility is less thanthree statute miles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal, it mustreturn to a predetermined locationwithinthe planned operating area and land or be recovered in accordance with the operating documents.20 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (consideringwind and forecast weather conditions) there is enoughpowerto fly at normal cruising speed to the intended landing point and land the UAwith 25 percentbattery powerremaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations underthe grant of exemption. This COAwill also require the operatorto request a Notice to Airman (NOT AM) not more than 72-hours in advance, but not less than48-hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance withthe exemption must be identified by serial number, registered in accordance with 14 C.F.R. part47, and have identification (NNumber) markings in accordance with 14 C.F.R. part45, Subpart C. Markings mustbe as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAmust comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the Pilot In Command (PIC) at the Ground Control Station (GCS) ofthe UAS anytime the UAS is operating. These documents mustbe made available to the Administratoror any law enforcement official uponrequest. 29. The UA mustremain clear andyieldthe right ofway to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all non-participating persons (persons otherthanthe PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protect non-participating persons from the UA and/or debris in the event ofan accident. The operator must ensure that non-participating persons remain under such protection. Ifa situation arises where non-participating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or;21 b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of suchvessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present anundue hazard, and;

c. Operations nearerto the PIC, SO, operatortrainees or essential persons do not present an undue hazardto those persons per§ 91.119(a). 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident orflight operationthattransgresses the lateral or vertical boundaries ofthe operational area, as defined by the applicable COA, must be reported to the FAA's UAS Integration Office (AFS-80) within 24-hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB website: www.ntsb.gov. 

### 2. ReasonsWhyAnExemption FromThe Requirements OfSection 61.113(a) And (b) Would NotAdversely Affect Safety. RSA Marketing submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to opetate the DJI Phantom 3 Professional and DJI Inspire 1UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 3 Professional orDJI Inspire 1UAS in a manner consistentwiththe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering RSA Marketing's proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See ExemptionNo. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 Professional orDJI Inspire 1UAS, RSA Marketing submits thatthe additional manned airmanship experience ofa commercially certificated pilotwould not correlate to the airmanship skills necessary for RSA Marketing's specific proposed flight operations. The FAAhas previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).22 RSAMarketingwill not allow any PIC to operate the DJI Phantom 3 Professional or DJI Inspire 1UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3 Professional or DJI Inspire 1UAS training and currency requirements, thatthe PIC is able to safely operate the DJI Phantom 3 Professional orDJI Inspire 1UAS in a manner consistentwiththis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC musthave accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25-hours oftotal time as a UAS rotorcraft pilot (with a minimum offive ofthose hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption). In additionto the hour requirements, the PIC must accomplishthree takeoffs and landings inthe preceding 90 days (for currency purposes). As inExemptionNos. 11062, 11138 and 11153, priordocumented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during RSAMarketing's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In ExemptionNo. 11062, the FAArequired thatpriorto conducting operations for the purpose ofmotionpicture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistentwith 14 CFR 61.51(b), 25-hours oftotal time as a UAS rotorcraft pilot including at least 10-hours logged as a UAS pilotwith a multi-rotorUAS. Priorto operations under ExemptionNo. 11062, the PIC must also have accumulated and logged a minimum of5-hours as a UAS pilot operatingthe same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimumhourrequirements to be inclusive ratherthan additive (i.e. 5-hours make and model time may be included in the 10-hours ofmulti-rotortime and the 10-hours maybe included in the total25-hours ofUAS rotorcraft time). In addition to the hour requirements, the PIC must accomplishthree takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency inthe skills necessary to safely conductthe petitioner's proposed operations. The FAA also finds thatprior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted underthe grant ofexemptionto accomplishthe required flight time. During training, proficiency and experience-building flights the PIC is required to operate theUA with appropriate distances in accordance with 14 C.F.R 91.119. ExemptionNo. 11138 at page 15. Accordingly, RSAMarketingwill ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Professional or DJI Inspire 1UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currencyrequirements, thatthe PIC is able to safely23 operate the DJI Phantom 3Professional or DJI Inspire 1UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 3. Reasons WhyAn Exemption From The Requirements OfSection 91.7(a) Would Not AdverselyAffect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, RSA Marketing will ensure thatthe DJI Phantom 3 Professional or DJI Inspire 1UAS is in an airworthy condition based uponthe UASs compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161). 4. Reasons WhyAn Exemption From The Requirements OfSection 91.121 Would Not AdverselyAffect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 3 Professional and DJI Inspire 1UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined withRSA Marketing's operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UAs within Visual Line ofSight (VLOS), at or below400 feet Above Ground Level (AGL), will ensure a level ofsafety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiationpoint is automatically established by the UASs at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 11150,11153,11156,11157,11158,11159,11160, 11161). 5. Reasons WhyAn Exemption From The Requirements OfSection 91.15l(b) Would NotAdverselyAffect Safety. A grant ofthis exemptionwould ensure an equivalent level ofsafety established by 14 C.F.R. Section 91. 151(b) as a result of(1) the technical specifications ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs; (2) the limitations onthe proposed flight24 operations; and (3) the location ofthe proposed flight operations. Accordingly, RSA Marketing will ensure that it will safely operate the battery powered DJI Phantom 3 Professional and DJI Inspire 1UAs during daylight hours in Visual FlightRules (VFR) conditions, with enough battery power to fly for atotal duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in ExemptionNo. 11109, the technical specifications ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs; the limitations onthe proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Professional and DJI Inspire 1UASs provide audible and visual warnings to the PIC at the GCS whenthe UAs experiences low-battery voltage, the first warning occurring at approximately 33 percent remaining battery power, and again at approximately 10 percent remaining battery power. Atthe critically low-battery level, the DJI Phantom and DJI Inspire 1UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less thanthe minimums prescribed in Section 91.151, including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062, 11063, 11064,11065,11066,11067,11080,11109,11110,11136,11138,11150,11153,11156, 11157,11158,11159,11160, 11161). 6. Reasons WhyAn Exemption From The Requirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would NotAdverselyAffect Safety. In seekingthis exemption, RSA Marketing submits that the equivalent level ofsafety with regard to the regulatory maintenance and alterationrequirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be metbecause RSA Marketing will use trained technicians to perform maintenance, alterations or preventive maintenance onthe UASs using the methods, techniques and practices prescribed in the operating documents (i.e. the RSA Marketing Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3Professional and DJI Inspire 1InstructionManual). Furthermore, RSA Marketing will document and maintain all maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1UASs.

Since the DJI Phantom 3 Professional and DJI Inspire 1UASs will be inspected as prescribed by the operating documents, RSA Marketing will maintainthe equivalent level25 ofsafety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe DJI Phantom 3 Professional and DJI Inspire 1User Manuals are attached hereto as Exhibit C and D; a copy ofthe DJI Phantom 3 Professional and DJI Inspire 1UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption sought will not adversely affect safety because RSAMarketing will use trained technicians to perform maintenance, alterations or preventive maintenance onthe UAS usingthe methods, techniques and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.
Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establishthat safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. In consideration ofRSAMarketing's proposed operating limitations, the operating documents, and thetechllicaLaspects ofthe DJI Phantom 3 Professional and DJI Inspire 1 UASs, RSAMarketing submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted reliefspecific to UAS incircumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161). 

### 7. The FAA MayPrescribeAny OtherConditions For Safe Operation.
In accordance with Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA) and 14 C.F.R. §21.16 entitledSpecial Conditions, RSA Marketingrequests that the FAA prescribe special conditions for the intended operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UAs for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for consideringwhether a UAS will create a hazard to users ofthe National Airspace System (NAS) orthe public, or otherwise pose a26 threat to national security; and further, provides the authority for suchUAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS inthe NAS. Likewise, the Administratormay prescribe special conditions pursuantto 14 C.P.R. §21.16, for operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs, since the airworthiness regulations of 14 C.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: Ifthe FAAfinds thatthe airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level ofsafety equivalent to that established in the regulations. See 14 C.P.R.§ 21.16. Therefore, in accordance withFMRA Section 333 and 14 C.P.R. § 21.16, the FAA may prescribe special conditions for RSA Marketing's intended operation ofthe DJI Phantom 3 Professional and DJI Inspire 1UASs, which contain such safety standards thatthe Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.P.R. Part21, SubpartH, and 14 C.F.R Sections 61. r13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which RSA Marketing Seeks Exemption:
RSA Marketing seeks exemptionfrom the requirements of 14 C.F.R Sections 61.113(a)&(b). 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and91.417(a) & (b). A BriefDescription OfThe Nature OfThe Exemption RSA Marketing Videography Seeks:
This exemption willpermitRSA Marketing to commercially operate an UnmannedAircraft System (UAS)for thepurpose of conductingaerialvideo andphotographyover certain areas of the UnitedStates. G. AnyAdditional Information, Views OrArguments Available To Support RSA Marketing's Request.27 This Petition is made pursuantto the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportationto determine ifcertainUAS may operate safely in the NAS. As such, RSA Marketing's request for exemptionmay be granted pursuantto the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for consideringwhether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, RSA Marketing will operate the DJI Phantom 3 Professional and DJI Inspire 1UASs safely in the NAS, without creating a hazard to users ofthe NAS, or the public, or otherwise pose athreatto national security.

### 28
CONCLUSION As set forth herein, RSA Marketing seeks an exemption pursuantto 14 C.F.R. § 11.61 and Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA), whichwill permit safe operationofthe DJI Phantom 3 Professional and DJI Inspire 1UASs commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAA Administratorwill be fulfilling the Congressional mandate ofthe FAAModernization and Reform Act of2012,while also advancingthe interests ofthe public, by allowing RSA Marketingto safely, efficiently and economically operate the DJI Phantom 3 Professional and DJI Inspire 

### 1UASs commercially withinthe NAS. WHEREFORE, in accordance withthe Federal AviationRegulations and the FAA Modernization and Reform Act of2012, Section 333,RSAMarketingrespectfullyrequests thatthe Administrator grantthis Petitionfor an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permitRSAMarketingto operate the DJI Phantom 3 Professional andDJI Inspire 1UASs commercially for the purpose of conducting aerial video and photography over certainareas ofthe United States. Dated: June 15,2015

Respectfully submitted, RSAMarketing

Bruce Rowley RSAMarketing, CEO/Principal 400 S. Commerce Wichita, KS 67202 Tel: (316)977-9600 Appendices: A- DJI Phantom 3 Professional Specifications Data Sheet B- DJI Inspire 1SpecificationsData Sheet C- DJI Phantom 3 Professional Manufacturer's User Manual D- DJI Inspire 1Manufacturer's User Manual E- Monthly Maintenance Log

### 29 APPENDIX-A
DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS 

### RSA Marketing only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground-breaking software, enabling the userto set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude, as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location informationto the PIC viathe linked monitor (smartphone/tablet devices). 1. 1DJI Phantom 3 Professional 1. 1. 1Aircraft 1.1.1.1 Supported Battery- DJI 5200mAHLiPo Battery 1.1.1.2 Weight (Battery & 

### Propellers Included)- 2lbs 11.810oz (1242g) 1.1.1.3 HoverAccuracy (Ready to Fly)- Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max YawAngular Velocity- 200°/s 1.1.1.5 MaxTilt Angel- 35° 1.1.1.6 Max Ascent Speed- 6m/s 1.1.1.7MaxDescent Speed- 2m/s 1.1.1.8 MaxFlight Speed- 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy- ±0.03° 1.1.2.3 Controllable Range- Pitch: -90° to 0° 1.1.2.4 Maximum Angular Speed- Pitch: 90°/s 1.1.3 Camera 1.1.3.1 Operating Temperature Range- 32°F to 1 04°F (0°C to 40°C) 1.1.3.2 Sensor Size- 1/2.3" 1.1.3.3 Effective Pixels- 14M 1.1.3.4 Resolution- 4384x3288 4.1.3.5 HD Video Recording- 1080p30 & 

### 720p 4.1.3.6 Recording Field ofView- 110°/85° 1.1.4 Transmitter 1.1.4.1 Operating Frequency- 5.728GHz-5.85GHz 1.1.4.2 CommunicationDistance (unobstructed)- FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)- 93dBm 1.1.4.4 TransmitterPower- FCC Compliance: 100mW 1.1.4.5 Working Voltage- 120mA@3.7V

### 30

1. 1.5 Range Extender 1.1.5.1 Operating Frequency- 2412-2462MHz 1.1.5.2 CommunicationDistance (unobstructed)- 500 to 700m 1.1.5.3 Transmitter Power

- 20dBm 1.1.5.4 Power Consumption

- 2W

APPENDIX-B
DJI INSPIRE 1TECHNICAL SPECIFICATIONS 

### RSA Marketing only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground-breaking software, enabling the user to set parameters whichwill not allow flight into controlled airspace. Parameters can also be setto limit flight to no higher than apredetermined and set altitude, as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location informationto the PIC viathe linked monitor (smartphone/tablet devices).
2.2 DJI Inspire 1
2.2.1 Aircraft 2.2.1.1 Model- T600 2.2.1.2 Weight (Battery Included)- 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)- Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 MaxAngular Velocity- Pitch: 300°/s; Yaw: 150°/s 2.2.1.5 MaxTilt Angle- 35° 2.2.1.6 Max Ascent Speed- 5m/s 2.2.1.7 MaxDescent Speed- 4m/s 2.2.1.8 Max Speed- 22m/s (ATTI mode, no wind- NOT RECOMMENDED) 2.2.1.9 MaxFlightAltitude- 4500m 2.2.1.10 MaxWind Resistance- 1 Om/s 2.2.1.11 MaxFlight Time- Approximately 18 minutes 2.2.1.12 Motor Model- DJI 3510 2.2.1.13 Propeller Model

- DJI 1345 2.2.1.14 OperatingTemperature Range- 14°F to 104°F (-10°C to 40°C) 2.2.1.15 Dimensions- 17 1;4" 

### x 17 %"

### x 12"
2.2.2 Gimbal 2.2.2.1 Model

- ZENMUSE X3 2.2.2.2 OutputPower (with camera)- Static: 9W; InMotion: 11W 2.2.2.3 Operating Current- Static: 750mA; In Motion: 900mA

### 31 2.2.2.4 Angular Vibration Range- ±0.03° 2.2.2.5 Mounting- Detachable 2.2.2.6 Controllable Range- Pitch: -90° to +30°; Pan: ±320° 2.2.2.7 Mechanical Range- Pitch: -125° to 45°; Pan: ±330° 2.2.2.8 Max Controllable Speed- Pitch: 120°/s; Pan: 180°/s 2.2.3 Camera 2.2.3.1 Name-X3 2.2.3.2 Model- FC350 2.2.3.3 Total Pixels- 12.76M 2.2.3.4 Effective Pixels- 12.4M 2.2.3.5 Image Max Size- 4000x3000 2.2.3.6 ISO Range- 100-3200 2.2.3.7 Field ofView- 94° 2.2.3.8 CMOS- Sony EXMOR 1/2.3" 2.2.3.9 HD Video Recording- UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 OperatingTemperature Range- 32°F to 104°F (0°C to 40°C) 2.2.4 Transmitter 2.2.4.1 Name- C1 2.2.4.2 Operating Frequency- 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 CommunicatingDistance (unobstructed)- 2000m 2.2.4.4 OutputPower- 9W 2.2.4.5 Operating Temperature Range- 14°F to 104°F (-10°C to 40°C) 2.2.4.6 Battery- 600mAh LiPo 2S32 APPENDIX-C
DJI Phantom 3 Professional Manufacturer's User Manual33 APPENDIX-D
DJI Inspire 1Manufacturer's UserManual

# PHANTOM l ,=>.=c:=;:::::=**:::;';.:.~]**


## User Manual D

### Using this manual

0 Warning & Important :\): Hints and Tips liGJ Reference

Read the following documents before using the Phantorn 3 Professional:
1. In the Box 2. Phantom 3 Professional UserManual 3. Phantom 3 Professional QuickStartGuide 4. Phantom 3 ProfessionalIAdvancedSafetyGuidelines andDisclaimer 5. Phantom 3 ProfessionalIAdvancedIntelligentFlightBatterySafetyGuidelines
We recornrnend that you watch all tutorial videos on the official DJI website and read the Disclaimer before you fly. Prepare for your first flight by reviewing the Phantorn 3 Professional Quick Start Guide and refer to the User Manual for rnore detailed information.

Please watch the tutorial videos at the link below, which demonstrates how to use Phantorn 3 Professional safely: http//www.dji.corn/product/phantorn-3/video

Download and install the DJI Pilot app before using the aircraft. Scan the OR code to the right**~~~~~~~. ~~~**  •-...J.·i.l.

. The Android version of the DJI Pilot app is compatible with Android 4.1.2 or later.**fi~i~** The iOS version ofthe DJI Pilot app is compatible with iOS 8.0 or later.**~ ~.·.~~~~** 

### ContentsUsing this manual Legends Read Before the First Flight Video Tutorials Download the DJI Pilot app

Product Profile Introduction Feature Highlights Preparing the Aircraft Aircraft Diagram Remote Controller Diagram

Aircraft Flight Controller Flight Mode Flight Status Indicator Return-to-Home (RTH) Smart RTH Low Battery RTH Failsafe RTH Vision Positioning System Flight Recorder Attaching and Detaching the Propellers DJI Intelligent Flight Battery

Remote Controller Remote Controller Profile Using the Remote Controller Remote Controller Status LED Linking the Remote Controller Remote Controller Compliance Version 2 2 2 2

6 6 7 8 8

11 11 11 12 12 13 14 14 16 16 17

23 23 27 28 29Camera and Gimbal
Camera Profile 31 Gimbal 32

DJI PilotApp Camera 35 Director 38 Store 38 Discovery 38
Flight Flight Environment Requirements 40 Flight Limits and No-FlyZones 40 Preflight Checklist 44 Calibrating the Compass 44 Auto Takeoff and Auto Landing 45 Flight Test 46 Starting/Stopping the Motors 46
Troubleshooting (FAQ)
Appendix Specifications 53 Intelligent Orientation Control (IOC) 55 FCC Compliance 56

4

# rofile

This section introduces the Phantom 3 Professional and lists the components of the aircraft and remote controller.

### Product Profile

The Phantom 3 Professional represents the next generation of OJI quadcopters. It is capable of capturing 4K video and transmitting an HD video signal out of the box. The built-in camera has an integrated gimbal to maximize stability while minimizing both weight and size. Even when no GPS signal is available, the Vision Positioning System allows the aircraft to hover accurately in place.

Camera and Gimbal: With the Phantom 3 Professional, you're shooting 4K video at up to 30 frames per second and capturing 12 megapixel photos that look crisper and cleaner than ever. An enhanced sensor gives you greater clarity, lower noise, and better pictures than any previous flying camera.
HD Video Downlink: The low-latency long range HD downlink is powered by an enhanced version of OJI Lightbridge.
DJI Intelligent Flight Battery: The 4480 mAh OJI Intelligent Flight Battery features upgraded battery cells and an advanced power management system. Flight Controller: The next-generation flight controller has been updated to provide a safer. more reliable flight experience. A newly implemented flight recorder stores critical data from each flight and the Vision Positioning System enhances hovering precision when flying indoors or in environments where GPS is unavailable.Phantom 3 Professional User Manual

Removing Gimbal Clamp Remove the gimbal clamp by sliding it to the right (when facing the nose of the aircraft), as shown below.

Attaching the Propellers: Mount the propellers with black dots on to motors with black axes and spin counter-clockwise to secure. Mount the propellers with sliver dots on to motors with sliver axes and spin clockwise to secure. Be sure all propellers are securely in place.

& Place all propellers onto the correct motors and tighten by hand to lock them in position. Preparing the Remote Controller: The mobile device holder is designed for securing tablet or mobile device. Tilt the mobile device holder to the desired position, then adjust the antennas so they are facing outward. 1. Press the button on the top right side of the mobile device holder to release the clamp, then adjust the

clamp to fit the size ofyour mobile device. 2. Secure your mobile device in the clamp by pressing down, and connect your mobile device to the remote controller using a USB cable. 3. Plug one end of the cable into the mobile device, and the other end into the USB port on the back of

the remote controller.

7Phantom 3 Professional User Manual

II 

# b 'I==11-----. .1ft (Q**~ ~'0**  ···' 

# ) [1] GPS [2] Propeller [3] Motor [4] Front LED Indicator [5] Landing gear [6] Gimbal and Camera [7] Aircraft Micro-USB Port [8] Aircraft Status Indicator [9] Intelligent Flight Battery [10] Vision Positioning Sensors [11] Antennas [12] Camera Micro-SO Card Slot [13] Camera Micro-USB Port [14] Link Button

[1] Antennas Relays aircraft control and video signal. [2] Mobile Device Holder Securely mounts your mobile device to the remote controller. [3] Control Stick Controls the orientation and movementofthe aircraft. [4] Return Home (RTH) Button Press and hold the button to initiate Return to Home (RTH).[5] Battery Level LEDs Displays the battery level of the remote controller. [6] Status LED Displays the remote controller's system status. [7] Power Button Used to turn the remote controller on and off. [8] RTH LED Circular LED around the RTH button displays RTH status.

[9] Camera Settings Dial Turn the dial to adjust camera settings. (Only functions when the remote controller is connected to a mobile device running the OJI Pilot app.) [1 0] Playback Button Playback the captured images orvideos. (Only functions when the remote controller is connected to a mobile device running the OJI Pilotapp.) [11] Shutter Button Press to take a photo If burst mode is selected, the set number of photos will be taken with one press. [12] Flight Mode Switch Switch between P-mode, A-mode, and F-mode. [13] Video Recording Button Press to start recording video. Press again to stop recording. [17] C1 Button Customizable through the OJI Pilot app. [18] C2 Button Customizable through the OJI Pilot app. [19] Power Port Connect to the DJI Phantom 3 Charger to charge the battery of the remote controller. Phantom 3 Professional User Manual

[14] Gimbal Dial Use this dial to control the tilt of the gimbal. [15] Mircro-USB Port Connect to a SO card reader to upgrade the firmware. [16] USB Port Connectto mobile device orto a USB port for firmware upgrade.

# Aircraft

This section introduces the features of the Flight Controller, Vision Positioning System. and the Intelligent Flight Battery

10

### Aircraft

The Phantom 3 Professional's flight controller features several important upgrades, including a new flight mode. Safety modes include Failsafe and Return-to-Home. These features ensure the safe return of your aircraft if the control signal is lost. The flight controller can also save critical flight data from each flight to the on-board storage device. The new flight controller also provides increased stability and a new air braking feature.

Three flight modes are available. The details of each flight mode are found below: P-mode (Positioning) : P-mode works best when GPS signal is strong. There are three different states of P-mode, which will be automatically selected by the Phantom 3 Professional depending on signal strength of GPS and Vision Positioning sensors : P-GPS: GPS and Vision Positioning both are available. The aircraft is using GPS for positioning. P-OPTI: Vision Positioning is available but the GPS signal strength is not sufficient. The aircraft is using only the Vision Positioning System for positioning. P-ATTI: Neither GPS nor Vision Positioning is available. The aircraft is using only its barometer for positioning, so only altitude can be stabilized. A-mode (Attitude): GPS and Vision Positioning System are not used for stabilization. The aircraft only uses its barometer. The aircraft can still automatically return to the home point if the control signal is lost and the Home Point was recorded successfully. F-mode (Function): Intelligent Orientation Control (IOC) is activated in this mode. For more information about IOC, refer to the IOC section in the Appendix. :<;/; Use the Flight Controller mode switch to change the flight rnode of the aircraft, refer to the "Flight Mode Switch" on Page 26 for more information.

The Phantom 3 Professional has Front LEOs and Aircraft Status Indicators. The positions of these LEOs are shown in the figure below:

The Front LEOs show the orientation of the aircraft. The Front LEOs glow solid red when the aircraft is turned on to indicate the front (or nose) of the aircraft. The Aircraft Status Indicators communicate the system status of the flight controller. Refer to the table belowfor more information about the Aircraft Status Indicators:
11l> ::; D Phantom 3 Professional User Manual

Norrnal -c'f!J:tfjriS:f:

..···· Red, Green and Yellow Flash Alternatively Turning On and Self Diagnostic Testing :ff?!.:¢1;..

.... Green and Yellow Flash Alternatively Warming Up :@.:······Green Flashes Slowly
:t/J!:X2 ······Green Flashes Twice :@

...... Yellow Flashes Slowly :warning ¢·

...... Fast Yellow Flashing :JBF

...... Slow Red Flashing !6):······Fast Red Flashing 

### :f/!f:· ·····Red Flashing Alternatively tf!J.·- Solid Red Safe to Fly (P-mode with GPS and Vision Positioning) Safe to Fly (P-mode with Vision Positioning but without GPS) Safe to Fly (A-mode but No GPS and Vision Positioning)

Remote Controller's Signal Lost Low Battery Warning Critical Battery Warning IMU Error Critical Error :IJ!l-.:.1$..-······ Red and Yellow Flash Alternatively Compass Calibration Required

The Return-to-Home (RTH) function brings the aircraft back to the last recorded Home Point. There are three types of RTH procedures: Smart RTH, Low Battery RTH, and Failsafe RTH. This section describes these three scenarios in detail.

Home Point If a strong GPS signal was acquired before takeoff, the Home Point is the location from which the aircraft was launched. The GPS signal strength is indicated by the GPS icon (**~,ull** ). The aircraft status indicatorwill blink rapidly when the home point is recorded.

Use the RTH button on the remote controller (refer to "RTH button" on page 26 for more information) or tap the RTH button in the DJI Pilot app and follow the on-screen instructions when GPS is available to initiate Smart RTH. The aircraft will then automatically return to the last recorded Home Point. You may use the remote controller's control sticks to control the aircraft's position to avoid a collision during the Smart RTH process. Press and hold the Smart RTH button once to start the process, and press the Smart RTH button again to terminate the procedure and regain full control ofthe aircraft.

12Phantom 3 Professional User Manual

The low battery level failsafe is triggered when the DJI Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. Users are advised to return home or land the aircraft immediately when prompted. The DJI Pilot app will display a notice when a low battery warning is triggered. The aircraft will automatically return to the Home Point if no action is taken after a ten-second countdown. The user can cancel the RTH procedure by pressing the RTH button on the remote controller. The thresholds for these warnings are automatically determined based on the aircraft's current altitude and distance from the Home Point.
The aircraft will land automatically if the current battery level can only support the aircraft long enough to descend from its current altitude. The user can still use the remote controller to alter the aircraft's orientation during the landing process.
The Battery Level Indicator is displayed in the DJI Pilot app, and is described below: SuffiCif-nt battt:ry 'J'

aircraft return to the Home Fly the aircraft point and land automatically, back and land Low battery The battery Aircraft status or "Cancel" to resume normal it as soon as level warning power is low. flight. If no action is taken, possible, then Please land the the aircraft will automatically stop the motors aircraft. go home and land after 10 and replace the seconds. Remote controller battery. will sound an alarm.
Critical Low The aircraft Aircraft status The DJI Pilot app display will Allow the aircraft to battery level must land indicator blinks flash red and the aircraft will descend and land start to descend. The remote warning immediately. RED quickly. controllerwill sound an alarm. automatically.

Estimated Estimated remaining remaining flight N/A N/A N/A based on current flight time battery level.

13Phantom 3 Professional User Manual
:\;): • When Critical battery level warning is triggered and the aircraft begins to land automatically, you may push the throttle upward to make the aircraft hover at its current altitude, giving you an opportunity to navigate to a more appropriate landing location. • The colored zones and markers on the battery level indicator bar reflect the estimated

remaining flight time. They are automatically adjusted according to the aircraft's current location and status.

If the Home Point was successfully recorded and the compass is functioning normally, Failsafe RTH will be automatically activated if the remote controller signal is lost for more than three seconds. The Returnto-Home process may be interrupted and the operator may regain control of the aircraft if the remote controller signal connection is re-established. Failsafe Illustration 1 Record Home Point

Blink1ng Green 4 Signal Lost Lasts (after 3 sec.)

>38

Fast Blinking Yellow 2 Confirming Home Point**~~1111** 

## y

Blinking Green 5 RTH (adjustable altitude)**v~::::::::::::::~**

# ___Y 

## 0 I :y**~** @ Fast Blinking Yellow 3 Remote Controller Signal Lost

Fast Blinking Yellow 6 Landing (after hovering for 5 sees) 

### T



## .. @ Fast Blinking Yellow 

### &

.The aircraft cannot avoid obstruction during the Failsafe RTH, therefore, it is important to set an suitable Failsafe altitude before each flight. Launch the DJI Pilot app and enter "Camera" and select "MODE> Advanced Settings > Failsafe mode" to set the Failsafe altitude. • The aircraft will stop its ascent and return to the Home Point immediately if the throttle stick is

moved during the Failsafe RTH procedure.

The DJI Vision Positioning System uses ultrasound and image data to help the aircraft maintain its current position. With the help of Vision Positioning, your Phantom 3 Professional can hover in place more precisely and fly indoors or in other environments where a GPS signal is not available. The main components of the Vision Positioning System are located on the bottom of your Phantom 3 Professional; they include [2] two ultrasonic sensors and [1] one monocular camera.

14Phantom 3 Professional User Manual Using Vision Positioning Vision Positioning is activated automatically when the Phantom 3 Professional is turned on. No further action is required. Vision Positioning is typically used in indoor environments, where GPS is unavailable. Using the sensors that are built into the Vision Positioning system, the Phantom 3 Professional can hover precisely even without GPS.**~.,___**

## ____ _____,./ 

# I -y-
. i 

## I**~** I I 

## 1/**~ ~I**  Follow the steps below to use Vision Pos1t1on1ng 

# ep

1. Toggle the flight mode switch toP-mode. ' ' 2. Place the aircraft on a flat surface. Note that the Vis1on Posit1on1ng system cannotwork

properly on surfaces without clear pattern vanat1ons. 3. Turn on the aircraft. The aircraft status indicator will flash green two times, which indicates the Vision Positioning system is ready. Gently push the throttle up to lift off and the aircraft will hover in place. & The performance of your Vision Positioning System is affected by the surface over which it is flying. The ultrasonic sensors may not be able to accurately measure distances when operating above sound-absorbing materials. In addition, the camera may not function correctly in suboptimal environments. The aircraft will switch from P-mode to A-rnode automatically if neither GPS nor Vision Positioning System are available. Operate the aircraft with great caution in the following situations: • Flying over monochrome surfaces (e.g. pure black, pure white, pure red, pure green). • Flying over a highly reflective surfaces. • Flying at high speeds(over 8 m/s at 2 meters or over 4 m/s at 1 meter). • Flying overwater or transparent surfaces. • Flying over moving surfaces or objects. • Flying in an area where the lighting changes frequently or drastically. • Flying over extremely dark (lux< 10) or bright (lux> 100,000) surfaces. • Flying over surfaces that can absorb sound waves (e.g. thick carpet). • Flying over surfaces without clear patterns ortexture. • Flying over surfaces with identical repeating patterns or textures (e.g. tiles with the sarne design). • Flying over inclined surfaces thatwill deflect sound waves away from the aircraft. ;\;): • Keep the sensors clean at all times. Dirt or other debris may adversely affect the effectiveness of the sensors. • Vision Positioning is only effective when the aircraft is at altitudes of 0.3 to 3 meters. • The Vision Positioning System may notfunction properly when the aircraft is flying overwater. • The Vision Positioning System may not be able to recognize pattern on the ground in low light

conditions (less than 100 lux) • Do not use other ultrasonic devices with frequency of40 KHz when Vision Positioning system is

in operation. • Vision Positioning System may not be able to stabilize the aircraft when flying close to the

ground (below 0.5 meters) atfast speeds

.. 15Phantom 3 Professional User Manual 

### 0 Keep the animals away from the aircraft when Vision Positioning system is activated. The sonar sensor emits high frequency sounds that are only audible to some animals.

Flight data is automatically recorded to the internal storage of the aircraft. This includes flight telemetry, aircraft status information, and other parameters. To access these data, connect the aircraft to the PC through the Micro-USB port and launch the OJI Pilot app.

Use only DJI approved propellers with your Phantom 3 Professional. The grey and black nuts on the propeller indicate where they should be attached and in which direction whey should spin. To attach the propellers properly, match the nut color with the motor axis color.**·~ropellers**

Figure Attach On Legends**Silv~r** Dol '\, \\" ,, ,,**~iack.Qbt:**

Motors with a grey axes Motors with a black axes Ell Lock :Turn the propellers in the indicated direction to mount and tighten. 

### 'D'l Unlock: Turn the propellers in the indicated direction to loosen and remove. Attaching the Propellers 1. Be sure to remove the warning stickers from the motors before attaching the propellers. 2. Attach the propellers with silver dots onto the motors with silver axes and spin the propellers clockwise

to secure them in place. Attach the propellers with black dots onto the motors with black axes and spin the propellers counter-clockwise to secure them in place. Be sure to tighten each propeller by hand before flight.

16Phantom 3 Professional User Hanual 

### 6 •Ensure propellers are attached to its corresponding motors, otherwise the aircraft cannottake off

. •Wear gloves when handling propellers. • Hand tighten each of the propellers on the corresponding motors to ensure it is attached firmly.
Detaching the Propellers Hold the motor in place with one hand, then spin the propeller in the indicated unlock direction. & · Check that the propellers and motors are installed correctly and firmly before every flight. • Ensure that all propellers are in good condition before each flight. DO NOT use aged, chipped,

or broken propellers. • To avoid injury, STAND CLEAR of and DO NOTtouch propellers or motors when they are spinning. • ONLY use original OJI propellers for a better and safer flight experience.

The OJI Intelligent Flight Battery has a capacity of 4480 mAh, a voltage of 15.2 V, and a smart charge/ discharge functionality. It should only be charged using an appropriate charger that has been approved by DJI.



### 6 The Intelligent Flight Battery must be fully charged before using it for the first time. Refer to "Charging the Intelligent Flight Battery" for more information. :\): Be aware that the output power ofthe supplied Phantom 3 Professional charger is 100W.

DJI Intelligent Flight Battery Functions 1. Battery Level Display: the LED indicators displaythe current battery level. 2. Battery Life Display: the LEOs display the current battery power cycle. 3. Auto-Discharging Function: To prevent swelling, the battery automatically discharges to below 65% of

total power when it is idle for more than ten days. It takes around two days to discharge the battery to 65%. It is normal to feel moderate heat being emitted from the battery during the discharge process. Discharge thresholds can be set in the OJI Pilot app. 4. Balanced Charging: Automatically balances the voltage of each battery cell when charging. 5. Overcharge Protection: Charging automatically stops when the battery is fully charged. 6. Temperature Detection: The battery will only charge when the temperature is betweenooc (32°F) and

40°C (104°F). 7. Over Current Protection: The battery stops charging when high amperage (more than 8 A) is detected. 8. Over Discharge Protection: To prevent over-discharge damage, discharging automatically stops when

the battery voltage reaches 12 V. 9. Short Circuit Protection: Automatically cuts the power supply when a short circuit is detected. 17